The IRS has released a report analyzing the uncertain tax positions taken by corporations during the 2011 tax year. The requirements for a corporation to be included in the analysis were the analyzed corporation had to have:

• Issued or be included in audited financial statements ;

• Assets equal to or greater than $50 million;

• Taken a tax position on its U.S. federal income tax return for 2011 or a prior tax year; and

• Recorded a reserve in its audited financial statements with respect to that tax position or did not record a reserve because the corporation expects to litigate the position.

While an analysis of the specific uncertain tax positions had not been made for 2011, in 2010 43% of the uncertain tax positions covered transfer pricing and research credit. Further the top four code sections referenced were IRC 41, 482, 263, and 162.

*A Coordinated Industry Case (CIC) is defined as a taxpayer and its’ effectively controlled entities that warrants application of team examination procedures and meets the point criteria outlined in the Internal Revenue Manual. An Industry Case (IC) is defined as a taxpayer and its’ effectively controlled entities that warrants application of team examination procedures and does not meet the definition of a Coordinated Industry case. IRM 4.46.2.4 – 4.46.2.6.2.